App Privacy Policy

This Privacy Policy explains how Sam Aitch Ltd (“we”, “us” or “our”) collects, uses and shares information when you (“you”) use the ¡Vale! mobile applications for iOS and Android (the “App”). It also explains the choices you have and your rights under data protection law.

This policy covers the App only. Our website has its own Website Privacy Policy. When you buy a subscription, download the App or back up your device, Apple and Google process your information under their own privacy policies, which this policy does not cover.

Who we are and how to contact us
The information we collect
How we use your information and our legal bases
How we share your information
International transfers
How long we keep your information
Your rights
Your choices
Security
Children
Third-party services
Additional information for US residents
Changes to this policy
Complaints

1. Who we are and how to contact us

The App is provided by Sam Aitch Ltd, a company registered in England and Wales under company number 17463030, whose registered office is at 317 Newman Road, Sheffield, S9 1LW, United Kingdom. Sam Aitch Ltd is the controller of the personal information described in this policy.

If you have any questions about this policy or how we handle your information, or wish to exercise your rights, contact us at admin@samaitch.com.

2. The information we collect

The App does not require an account, and it never asks for your name, email address, telephone number or postal address. If you choose to email us, for example to send feedback, we receive what you send (see section 2.4).

2.1 Information stored only on your device

The App stores the following information on your device so that it can work. This information is not sent to us or to anyone else, and we cannot access it.

Information you provide: your answers in the App’s introduction (your level of Spanish, your reasons for learning, your goals, the situations that interest you and how much time you have each day), including any text you choose to type in an optional free-text field.
Your settings: for example, the language used for explanations, whether the daily reminder is on and its time, and the audio playback speed.
Information created as you use the App: your progress through the scenes, the expressions you have seen and saved, and your review history.
Your consent choice for advertising measurement (see section 2.2).
Your answer to the App’s question “Are you enjoying ¡Vale!?”, which is used to decide whether to ask for your feedback.
Feedback you type in the App’s feedback screen. It is not stored, and goes nowhere unless you send it from your own email app (see section 2.4).

If you back up your device (for example, to iCloud or to your Google account), this information may be included in that backup. Backups are provided by Apple or Google under your agreement with them.

If, and only if, you agree to advertising measurement, the App sends the following information to our measurement provider, Tenjin, Inc. (“Tenjin”), each time you open the App:

On iOS: the App’s identifier for vendors (IDFV); your device’s advertising identifier (IDFA), but only if you also allow tracking in Apple’s App Tracking Transparency prompt; and Apple’s Search Ads attribution token.
On Android: your device’s advertising ID, the App Set ID, and the Google Play install referrer (which indicates where the App was installed from).
On both: your device model and operating system version, the App’s version, your device’s language, region and time zone, and your IP address.

Tenjin uses this information to work out which advertising campaign, if any, led to your install, and in doing so shares information about the install with the advertising network concerned (see section 4).

We ask for your consent in the App’s introduction. If you do not give it, none of this information is sent to Tenjin or to any advertising network. You can withdraw your consent at any time (see section 8).

The App does not contain software from advertising networks such as Meta, Google or Reddit, and it does not show advertisements.

2.3 Information we receive from third parties

Apple and Google process your subscription purchases. The App receives confirmation of whether you have an active subscription. We receive sales and financial reports, which may include the plan purchased, the date and the country of purchase. We never receive your payment card details.
Apple SKAdNetwork. On iOS, Apple’s operating system may report that an install followed an advertisement, to the advertising network and to Tenjin. These reports are generated by Apple, are aggregated and delayed, and do not contain identifiers for you or your device.

2.4 Information you send us

Sending us feedback, or otherwise emailing us, is optional. If you do, we receive your email address, any name set in your email account, your message and anything you attach. Feedback sent from the App’s feedback screen also includes the App’s version, your device’s operating system version and your device’s model, which the App adds to the message where you can see them before you send it.

The App does not send this information itself: it opens your own email app, which sends the message through your email provider.

3. How we use your information and our legal bases

Under UK and EU data protection law, we must have a legal basis for each use of your personal information.

Purpose	Information used	Legal basis
To provide the App and its features	Information stored on your device (section 2.1), which we do not receive	Not applicable: we do not process this information ourselves
To provide and manage your subscription	Subscription status and sales reports (section 2.3)	Performance of our contract with you; legal obligation (accounting and tax records)
To measure which of our advertisements lead to installs of the App, including confirming with the advertising network concerned whether an install followed one of its advertisements	Information described in section 2.2	Your consent (Article 6(1)(a) UK GDPR and EU GDPR), including consent to access information on your device as required by the Privacy and Electronic Communications Regulations and the EU ePrivacy Directive
To read and reply to your feedback and other messages, and to improve the App	Information described in section 2.4	Our legitimate interests in answering you and in improving the App
To comply with the law, respond to lawful requests and protect our legal rights	Any of the above, as necessary	Legal obligation; our legitimate interests in establishing, exercising or defending legal claims

We do not use your information to make decisions about you based solely on automated processing. The App itself does not show advertisements.

We do not sell your personal information. We share it only as follows:

Service providers. Tenjin processes the information described in section 2.2 on our behalf, as our processor, to provide us with advertising measurement. Apple Distribution International Limited provides our email service (iCloud Mail), which stores the emails you send us (section 2.4) on our behalf.
Advertising partners. We advertise the App on the following networks. Where you have consented to advertising measurement, Tenjin shares information about your install and use of the App with the network whose advertisement led to it, such as your device’s advertising identifier (on iOS, only if you allowed tracking), the date and time of the install or app open, and the campaign it is attributed to. On iOS, Apple’s Search Ads attribution token is sent to Apple. The networks use this information to attribute and measure our campaigns and may also use it under their own terms, for example to improve how advertisements are delivered. They act as independent controllers:
- Meta Platforms Ireland Limited and Meta Platforms, Inc. (Facebook and Instagram advertising);
- Google Ireland Limited and Google LLC (Google Ads);
- Reddit, Inc. (Reddit Ads);
- Apple Distribution International Limited (Apple Search Ads).
App platforms. Apple and Google provide the App Store and Google Play, process subscription payments and provide device backups. They act as independent controllers under their own terms and privacy policies.
Professional advisers, such as lawyers and accountants, where necessary and under duties of confidentiality.
Authorities, where we are required to do so by law or to protect our legal rights.
Business transfers. If our business, or the App, is sold, merged or reorganised, your information may be transferred to the new owner, who will be bound by this policy.

5. International transfers

Tenjin, our advertising partners, Apple (including as our email provider) and Google may process personal information in the United States and in other countries outside the United Kingdom and the European Economic Area. Where we transfer personal information outside the UK or the EEA, we ensure that it is protected by an appropriate safeguard, such as an adequacy decision (including the EU–US Data Privacy Framework and its UK extension, where the recipient is certified), or the European Commission’s Standard Contractual Clauses together with the UK International Data Transfer Addendum. You can contact us for more information about these safeguards.

6. How long we keep your information

Information stored on your device remains there until you delete it, the App’s data or the App.
Advertising measurement information is kept for as long as necessary to measure the performance of our advertising, and no longer than our engagement with Tenjin.
Emails and feedback you send us are kept for up to 24 months after our last exchange with you, then deleted, unless we need them for longer to establish, exercise or defend legal claims.
Sales and financial records are kept for as long as required by tax and accounting law (in the United Kingdom, generally six years).

7. Your rights

Under UK and EU data protection law, you have the right to:

access the personal information we hold about you;
rectification of inaccurate or incomplete information;
erasure of your information in certain circumstances;
restrict our use of your information in certain circumstances;
object to our use of your information where we rely on legitimate interests;
data portability, where we rely on your consent or a contract; and
withdraw your consent at any time, without affecting the lawfulness of processing before you withdrew it.

To exercise any of these rights, contact us at admin@samaitch.com. We may need to ask for information to verify your identity, for example the advertising identifier of your device. We will respond within one month, which may be extended by two further months for complex requests, in which case we will tell you.

Because most of the information described in this policy never leaves your device, we usually hold very little personal information about you, beyond any emails you have sent us. Our advertising partners hold the information they receive as independent controllers; you can also exercise your rights with them directly, using the contact details in their privacy policies (section 11).

8. Your choices

Advertising measurement. You can give or withdraw your consent at any time in the App, under Ajustes → Privacidad → Medición de anuncios. When you withdraw it, the App stops sending information to Tenjin, and so no further information about your use of the App reaches our advertising partners.
Advertising networks’ settings. Meta, Google and Reddit offer their own settings for the advertising you see, in your account settings with each of them.
Tracking on iOS. You can allow or deny tracking for the App in your device’s Settings → Privacy & Security → Tracking.
Advertising ID on Android. You can reset or delete your device’s advertising ID in your device’s Google or privacy settings.
Feedback. Sending us feedback is optional. You can ask us at any time to delete the emails you have sent us.
Notifications. You can turn the daily reminder off in the App or in your device’s notification settings.
Deleting your information. You can delete the information stored on your device by deleting the App.

9. Security

We use appropriate technical and organisational measures to protect personal information. The App does not transmit your learning information at all, and the information sent for advertising measurement is sent over encrypted connections. Feedback you email us travels through your email provider and is stored by ours. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

10. Children

The App is not directed to children under the age of 16, and its content includes vulgar and offensive language as part of what it teaches. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

11. Third-party services

The App relies on services provided by third parties, whose own privacy policies apply to the information they process:

Apple: apple.com/legal/privacy
Google: policies.google.com/privacy
Tenjin: tenjin.com/privacy
Meta: facebook.com/privacy/policy
Reddit: reddit.com/policies/privacy-policy

12. Additional information for US residents

This section applies to residents of US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act.

Categories of personal information collected. In the past 12 months, and only where you consented to advertising measurement, we have collected:

identifiers, such as device advertising identifiers, the identifier for vendors, the App Set ID and IP address; and
internet or other electronic network activity information, such as the install referrer and attribution tokens, and device and app information; and
general geolocation, such as country or region derived from your device settings or IP address.

We collect this information from your device, for the purpose of measuring our advertising, as described in sections 2 and 3. We disclose it to our service provider Tenjin for that business purpose, and, through Tenjin, information about your install reaches the advertising partners listed in section 4.

If you email us, for example to send feedback, we also collect from you:

identifiers, namely your email address and any name set in your email account; and
the contents of your messages, including the App and device information added to feedback sent from the App.

We use this information to answer you and to improve the App, as described in sections 2.4 and 3, and disclose it only to our email provider, as a service provider, for that business purpose. We do not sell or share it.

Sale and sharing. We do not sell your personal information for money. Because our advertising partners may use the information they receive under their own terms, providing it to them may be considered “sharing” for cross-context behavioural advertising, or “targeted advertising”, under some state laws. It happens only if you consent to advertising measurement, and you can opt out at any time by turning off Ajustes → Privacidad → Medición de anuncios in the App (and, on iOS, by not allowing tracking). We do not collect sensitive personal information.

Your rights. Subject to applicable law, you have the right to know what personal information we have collected about you, to request its deletion, to request correction of inaccurate information, to opt out of sharing for targeted advertising, and not to be discriminated against for exercising these rights. You may make a request yourself or through an authorised agent by contacting us at admin@samaitch.com. We will verify your request before responding.

13. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top of this page shows when it was last changed. If we make material changes, for example to the information the App collects, we will take reasonable steps to let you know, such as a notice in the App, and, where required by law, ask for your consent again.

14. Complaints

If you have a concern about how we handle your personal information, please contact us first at admin@samaitch.com so that we can try to resolve it.

You also have the right to lodge a complaint with a data protection supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (ico.org.uk). If you live in the European Economic Area, you may complain to the supervisory authority in your country, such as the Agencia Española de Protección de Datos in Spain (aepd.es).